Filing # 46667693 E-Filed 09/20/2016 12:30:33 PM11. Defendant, PAUL FELDMAN, P.A., is a Florida corporation with its principal place of business at 2750 Northeast 185th Street, Suite

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

JAVIER NAVARRO VELASCO, as Trustee of FICREA S.A. DE C.V., SOCIEDAD FINANCIERA POPULAR, (In Liquidation), Plaintiff, v. RAFAEL ANTONIO OLVERA AMEZCUA, RAFAEL ALEJANDRO OLVERA SILVA, SUSANA SILVA TORTOLERO DE OLVERA, LEADMAN TRADE INC, SAMUEL STRAUCH, ALBERTO GALANTE, PAUL FELDMAN, P.A., LAW OFFICE OF JOHN F. FUINI, JR., PC, SERBER & ASSOCIATES, P.A., 2137 HAYES INC, 6308 DUVAL DR INC, ARION GROUP, LLC, CAPITAL LETTER INVESTMENTS, LLC, CREST 1123 CORP., CREST 1411 CORP., CREST 1411-725 CORP., CREST 1412 CORP., CREST 1414 CORP., CREST 1417 CORP., CREST 311 CORP., CREST 322 CORP., CREST 818 CORP., ELEANOR ASSET LLC, HIGHLAND SAT INVESTMENTS, LLC, INLAND ASSET CAPITAL, LLC, LT 103 AVENTURA ONE INC, LT 150 OFFICES INC, LT 150 PARKING INC, LT 77 NW 77 INC, LT ARLEN HOUSE LLC, LT ARTECH LLC, LT AVENTURA ONE LLC,

CASE NO: COMPLAINT

Filing # 46667693 E-Filed 09/20/2016 12:30:33 PM

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LT AVONDALE LLC, LT BROWARD PROPERTIES INC, LT COASTAL TOWERS LLC, LT FLORIDA CITY LLC, LT IDEAL APARTMENTS LLC, LT LAKE WORTH INC, LT LAUDERDALE LAKES LLC, LT N 1380 KROME INC, LT RIVIERA BEACH LLC, LT SAN ANTONIO SERIES B LLC, LT SEACOAST LLC, LT W PALM BEACH LLC, LT WELLS HOLLYWOOD LLC, NORTH ASSET CAPITAL LLC, RED KAIZEN INVESTMENTS, LLC, ROA 1406 LLC, ROA BH 2404 LLC, ROA CT LLC, ROA OVERSEAS LLC, ROCKWELL ASSET CAPITAL, LLC, UNIT 901 OCEANVIEW INC., Defendants.

COMPLAINT

COMES NOW the Plaintiff, JAVIER NAVARRO VELASCO, as Trustee of

FICREA S.A. DE C.V., SOCIEDAD FINANCIERA POPULAR, (In Liquidation) by

and through his undersigned attorneys, and sues the Defendants, RAFAEL

ANTONIO OLVERA AMEZCUA, SUSANA SILVA TORTOLERO DE OLVERA,

RAFAEL ANTONONIO OLVERA SILVA, LEADMAN TRADE INC, ALBERTO

GALANTE, SAMUEL STRAUCH, PAUL FELDMAN, P.A., LAW OFFICE OF JOHN

F. FUINI, JR., PC, SERBER & ASSOCIATES, P.A., 2137 HAYES INC, 6308

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DUVAL DR INC, ARION GROUP, LLC, CAPITAL LETTER INVESTMENTS, LLC,

CREST 1123 CORP., CREST 1411 CORP., CREST 1411-725 CORP., CREST

1412 CORP., CREST 1414 CORP., CREST 1417 CORP., CREST 311 CORP.,

CREST 322 CORP., CREST 818 CORP., ELEANOR ASSET LLC, HIGHLAND SAT

INVESTMENTS, LLC, INLAND ASSET CAPITAL, LLC, LT 103 AVENTURA ONE

INC, LT 150 OFFICES INC, LT 150 PARKING INC, LT 77 NW 77 INC, LT ARLEN

HOUSE LLC, LT ARTECH LLC, LT AVENTURA ONE LLC, LT AVONDALE LLC,

LT BROWARD PROPERTIES INC, LT COASTAL TOWERS LLC, LT FLORIDA

CITY LLC, LT IDEAL APARTMENTS LLC, LT LAKE WORTH INC, LT

LAUDERDALE LAKES LLC, LT N 1380 KROME INC, LT RIVIERA BEACH LLC,

LT SAN ANTONIO SERIES B LLC, LT SEACOAST LLC, LT W PALM BEACH LLC,

LT WELLS HOLLYWOOD LLC, NORTH ASSET CAPITAL LLC, RED KAIZEN

INVESTMENTS, LLC, ROA 1406 LLC, ROA BH 2404 LLC, ROA CT LLC, ROA

OVERSEAS LLC, ROCKWELL ASSET CAPITAL, LLC, UNIT 901 OCEANVIEW

INC., and alleges:

Nature of Action

1. This is an action brought by JAVIER NAVARRO VELASCO, as the

court-appointed Trustee for FICREA S.A. DE C.V. SOCIEDAD FINANCIERA

POPULAR (In Liquidation) (“FICREA”), arising out of violations of Florida’s Civil

Remedies for Criminal Practices Act, Florida Statutes § 772.101 et seq.,

Florida’s Uniform Fraudulent Transfer Act, Florida Statutes § 726.101 et seq.,

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requests for injunctive relief pursuant to Florida Statutes § 895.05, and

common-law claims for unjust enrichment/constructive trust, conversion,

breach of fiduciary duty, aiding and abetting breach of fiduciary duty and

injunctive relief.

2. Plaintiff is seeking to recover at least US $65,000,000 stolen from

FICREA by its former principal, who concealed the stolen proceeds and

hindered the recovery thereof by depositing them principally in United States

bank accounts to be used to purchase personal and real property located in

South Florida and elsewhere.

The Parties

3. FICREA was an organization known as a “Sociedad Financiera

Popular” [a micro-finance company] (“SOFIPO”), established in accordance with

the laws of the United Mexican States (“Mexico”).

4. Plaintiff, JAVIER NAVARRO VELASCO (“NAVARRO”), a citizen of

Mexico, has been appointed Trustee of FICREA, which is currently in the

process of liquidation in Mexico. NAVARRO, as Trustee of FICREA, is

empowered with the authority to take any action, including the present action,

to recover assets stolen from FICREA.

5. Defendant, RAFAEL ANTONIO OLVERA AMEZCUA, (“OLVERA

AMEZCUA”) is a resident of Miami-Dade County, Florida.

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6. Defendant, RAFAEL OLVERA SILVA, (“OLVERA SILVA”) is a

resident of Miami-Dade County, Florida. Defendant, OLVERA SILVA, is the son

of Defendant, OLVERA AMEZCUA.

7. Defendant, SUSANA SILVA TORTOLERO DE OLVERA, (“SILVA

TORTOLERO”) is a resident of Miami-Dade County, Florida.

8. Defendant, LEADMAN TRADE INC, is a Florida corporation with its

principal place of business at 20900 Northeast 30th Avenue, Suite 307,

Aventura, Florida 33180.

9. Defendant, ALBERTO GALANTE, (“GALANTE”) is a real estate

broker who maintains his principal place of business at 20533 Biscayne

Boulevard, Suite 373, Aventura, Florida 33180.

10. Defendant, SAMUEL STRAUCH, (“STRAUCH”) is a real estate

broker who maintains his principal place of business at 1680 Michigan

Avenue, Suite 1024, Miami Beach, Florida 33139.

11. Defendant, PAUL FELDMAN, P.A., is a Florida corporation with its

principal place of business at 2750 Northeast 185th Street, Suite 203,


12. Defendant, LAW OFFICE OF JOHN F. FUINI, JR., PC, is a Texas

professional corporation with its principal place of business at 6243 West

Interstate 10, Suite 590, San Antonio, Texas 78201. The LAW OFFICE OF

JOHN FUINI, JR., PC is subject to the jurisdiction of this Court because it

communicated with individuals within Miami-Dade County, Florida, regarding

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the transfer of proceeds and received proceeds from individuals within Miami-

Dade County, Florida, in furtherance of the scheme to deprive the Plaintiff of

the proceeds at issue and utilized those proceeds to purchase assets as a part

of the scheme described herein.

13. At all times material hereto, Defendant, LAW OFFICE OF JOHN F.

FUINI, JR., PC, although existing as a corporation outside of the State of

Florida, has had and continues to have extensive contacts with the State of

Florida in that:

a.) The Defendant conducts business in the State of Florida;

b.) The Defendant is engaged in substantial and not isolated activities

within the State of Florida;

c.) The Defendant sold the services which are the subject of the

instant action in the State of Florida; and/or

d.) The Defendant provided services which are the subject of the

instant action in the State of Florida.

14. Defendant, SERBER & ASSOCIATES, P.A., is a Florida corporation

with its principal place of business at 2875 Northeast 191 Street, Suite 801,


15. Defendants,

2137 HAYES INC, 6308 DUVAL DR INC, CREST 1123 CORP., CREST 1411 CORP., CREST 1411-725 CORP., CREST 1412 CORP.,

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CREST 1414 CORP., CREST 1417 CORP., CREST 311 CORP., CREST 322 CORP., CREST 818 CORP., LT 103 AVENTURA ONE INC, LT 150 OFFICES INC, LT 150 PARKING INC, LT 77 NW 77 INC, LT BROWARD PROPERTIES INC, LT LAKE WORTH INC, LT N 1380 KROME INC,

are Florida corporations with their principal place of business at 20900

Northeast 30th Avenue, Suite 307, Aventura, Florida 33180.

16. Defendants,

ELEANOR ASSET LLC, LT ARLEN HOUSE LLC, LT ARTECH LLC, LT AVONDALE LLC, LT AVENTURA ONE LLC, LT COASTAL TOWERS LLC, LT FLORIDA CITY LLC, LT IDEAL APARTMENTS LLC, LT LAUDERDALE LAKES LLC, LT RIVIERA BEACH LLC, LT SAN ANTONIO SERIES B LLC LT SEACOAST LLC, LT W PALM BEACH LLC, LT WELLS HOLLYWOOD LLC, ROA 1406 LLC, ROA BH 2404 LLC, ROA CT LLC, and ROA OVERSEAS LLC,

are limited liability companies with their principal place of business at 20900

Northeast 30th Avenue, Suite 307, Aventura, Florida 33180.

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17. Defendant, UNIT 901 OCEANVIEW INC., is a Florida corporation

with its principal place of business at 1000 Brickell Avenue, Suite 400, Miami,

Florida 33131.

18. Defendants, ARION GROUP, LLC, INLAND ASSET CAPITAL, LLC,

NORTH ASSET CAPITAL LLC, and ROCKWELL ASSET CAPITAL, LLC, are

Texas limited liability companies with their principal place of business at

12002 Bandera Road, Suite 102, Helotes, Texas 78023-4669.

19. Defendants, CAPITAL LETTER INVESTMENTS, LLC, HIGHLAND

SAT INVESTMENTS, LLC, and RED KAIZEN INVESTMENTS, LLC, are Texas

limited liability companies with their principal place of business at 20079

Stone Oak Parkway, Suite 1290, San Antonio, Texas 78258-7028.

20. The Defendants listed in paragraphs 5-10, (collectively the

“PRINCIPAL DEFENDANTS”) each individually and collectively worked together

to advance their interests in, and to participate in, the criminal scheme

described herein.

21. The Defendants listed in paragraphs 11-14 (collectively the

“PROFESSIONAL DEFENDANTS”) each individually provided significant

professional services to Defendants, OLVERA AMEZCUA, OLVERA SILVA, and

LEADMAN TRADE INC, to advance their interests as described herein.

22. The Defendants listed in paragraphs 15-19 (collectively the

“PROPERTY DEFENDANTS”) were dominated, controlled, and used as mere

instrumentalities of Defendants, OLVERA AMEZCUA and OLVERA SILVA, to

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advance their interests in, and to participate in, the criminal scheme described

herein.

Jurisdiction and Venue

23. Defendants are subject to personal jurisdiction in this forum in

that the causes of action alleged herein arise out of the acts of operating,

conducting, engaging in, or carrying on a business or business venture in this

state or having an office or agency in this state; conspiring to or committing a

tortious act within this state; and/or owning, using, possessing, or holding a

mortgage or other lien on any real property within this state.

24. In the alternative, Defendants have engaged in substantial and not

isolated activities within the State of Florida regardless of whether Plaintiff’s

claims arise out of those activities.

25. Venue is proper because one or more of the Defendants reside

here, the cause of action accrued here, and a substantial part of the assets in

litigation is located here.

General Allegations

A. Overview of Defendants’ Scheme to Transfer and Hide Funds Stolen From Plaintiff

26. Over a period from approximately July 2013 through August 2014,

Defendant, OLVERA AMEZCUA, and persons acting under his direction, stole

at least US $65,000,000.00 from FICREA and removed those funds from

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Mexico largely to the United States, using an extensive United States operation

created by the PRINCIPAL DEFENDANTS, the PROPERTY DEFENDANTS, and

others acting under their direction to hide the stolen funds in numerous assets

located principally in Florida.

27. Specifically, under the direction of FICREA’s President and 99%

shareholder, OLVERA AMEZCUA, the funds stolen from FICREA were used to

build a money-laundering empire (the “Enterprise”) that includes at least 30

companies located in Florida and throughout the United States, at least 100

real estate holdings, multiple vehicles, and substantial banking assets located

in the State of Florida and elsewhere, among other assets. The Enterprise,

orchestrated in large part through OLVERA AMEZCUA’S base of operations in

Miami-Dade County, Florida, involved the transfer of millions of dollars stolen

from FICREA to the United States and elsewhere, the receipt of those stolen

funds in the United States, and the use of those stolen proceeds to buy and

create companies controlled by OLVERA AMEZCUA, which were then utilized

to purchase homes, investment properties, yachts, automobiles, and other

assets.

B. The FICREA Scheme

28. On December 21, 2000, LEADMAN TRADE, S.A. DE C.V.

(“LEADMAN TRADE (MEXICO)”) was established in Mexico by OLVERA

AMEZCUA, who was 99% shareholder, as well as President. OLVERA

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AMEZCUA remained President of LEADMAN TRADE (MEXICO) at all times

material hereto.

29. On April 27, 2005, FICREA, S.A. DE C.V. was established in

Mexico, and on June 17, 2008, the Comisión Nacional Bancaria y de Valores

[Mexican National Banking Commission] (“CNBV”) granted FICREA

authorization to act as an entry-level SOFIPO (a Mexican micro-finance

institution with limited banking and savings and loan services). On May 13,

2011, OLVERA AMEZCUA acquired 98.64% of FICREA. OLVERA AMEZCUA

controlled FICREA at all times material hereto.

30. At all times relevant hereto, OLVERA AMEZCUA operated FICREA

by advertising lucrative returns on deposits to the Mexican public. At first,

deposit growth was small, but, as word spread, the number of investors and

the volume of deposits received increased exponentially.

31. On August 24, 2009, BAUS AND JACKMAN LEASING, S.A. DE

C.V. (“B&J”) was established in Mexico by OLVERA AMEZCUA, who was a 99%

shareholder, as well as President. OLVERA AMEZCUA remained President of

B&J at all times material hereto.

32. On August 10, 2011, MONKA COMERCIA, S.A. DE C.V. (“MONKA”)

was established in Mexico by OLVERA AMEZCUA, who was a 99% shareholder,

as well as President. OLVERA AMEZCUA remained President of MONKA at all

times material hereto.

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33. On August 22, 2011, the CNBV ordered that FICREA be audited,

and from August 29, 2011, to October 11, 2011, the CNBV carried out an

Ordinary Inspection Audit. During this audit, the CNBV detected various

irregularities and requested that corrective action be taken.

34. On August 24, 2011, FICREA entered into the first of several

contracts with B&J, through which FICREA would outsource its administrative

and management operations to B&J, which was owned and controlled by

OLVERA AMEZCUA.

35. The contracts contained a provision under which FICREA agreed to

pay B&J an advance, against which B&J was to bill periodically. The provision

also required B&J to return any unused portion of the advance to FICREA,

which never occurred on any occasion. B&J is a related party under Mexican

law because, at all times relevant, it was owned and controlled by OLVERA

AMEZCUA.

36. B&J proceeded to request and receive advances of FICREA funds

ostensibly to pay for FICREA’s operating expenses. The invoices and

corresponding advances were part of a scheme for OLVERA AMEZCUA to

syphon millions of dollars out of FICREA to OLVERA AMEZCUA. A substantial

portion of FICREA funds were stolen from FICREA in this manner.

37. In addition, under the control and direction of OLVERA AMEZCUA,

FICREA initiated a process by which funds would be channeled through

LEADMAN TRADE (MEXICO), also owned by OLVERA AMEZCUA. Specifically,

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under the direction of OLVERA AMEZCUA, monies loaned by FICREA to its

clients would be routed through LEADMAN TRADE (MEXICO). Conversely,

repayments by FICREA loan recipients to FICREA of loans would also be routed

through LEADMAN TRADE (MEXICO). These arrangements created another

mechanism by which OLVERA AMEZCUA was able to syphon millions of

dollars out of FICREA. A substantial portion of FICREA funds were stolen from

FICREA in this manner.

38. Furthermore, under the control and direction of OLVERA

AMEZCUA, FICREA initiated a process by which funds would be channeled

through MONKA, also owned by OLVERA AMEZCUA. Specifically, under the

direction of OLVERA AMEZCUA, monies loaned by FICREA to its clients would

also be routed through MONKA. These arrangements created yet another

mechanism by which OLVERA AMEZCUA was able to syphon millions of

dollars out of FICREA. A substantial portion of FICREA funds were stolen from

FICREA in this manner.

39. From November 20, 2012, to February 7, 2013, the CNBV carried

out an Ordinary Inspection Audit. The CNBV again detected various

irregularities, including improper activities with entities related to and under

the control/ownership of OLVERA AMEZCUA, double recording of credit

transactions, and assignments of receipt and payment rights on FICREA loans.

As a result of these irregularities, the CNBV requested that immediate

corrective action be taken.

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40. OLVERA AMEZCUA, knowing that the banking authorities were

investigating his illicit activities, took action to transfer the stolen proceeds

beyond the reach of the Plaintiff. For example, on July 1, 2013, B&J initiated a

series of wire transfers of FICREA funds from accounts held by B&J in Mexican

banks (CIBanco S.A. and Banco Base S.A.) to various accounts in the United

States. Over a span of 14 months, there were 711 wire transfers for a total

amount of US $47,121,551.31 of FICREA funds. These wire transfers did not

correspond to any legitimate business purpose, and were made, knowing that

the funds represented monies being stolen from FICREA, for the purpose of

placing the stolen proceeds of the scheme beyond the reach of the Plaintiff.

41. Furthermore, on July 1, 2013, B&J started transferring FICREA

funds from accounts held by B&J (in CIBanco S.A) to various accounts in

Spain. Over a span of approximately 14 months, there were 255 wire

transfers, for a total amount of EUR €8,853,541.71. These wire transfers did

not correspond to any legitimate business purpose, and were made, knowing

that the funds represented monies being stolen from FICREA, for the purpose

of transferring the stolen proceeds of the scheme beyond the reach of the

Plaintiff.

42. Furthermore, on August 8, 2013, OLVERA AMEZCUA ordered that

FICREA start transferring money stolen from FICREA from Mexico to the

United States. There were a total of five wires over the span of ten months, to

different recipients, for a total of US $381,631.51. These wire transfers did not

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correspond to any legitimate business purpose, and were made, knowing that

the funds represented monies stolen from FICREA, for the purpose of

transferring the stolen proceeds of the scheme beyond the reach of the Plaintiff.

43. From June 16, 2014, to August 1, 2014, the CNBV carried out an

emergency Special Inspection Audit to verify the financial and operational

status of FICREA. By this point, OLVERA AMEZCUA knew that the authorities

would soon take action, so he increased his efforts to transfer the stolen

proceeds abroad.

44. Accordingly, on July 16, 2014, LEADMAN TRADE (MEXICO) made

the first transfer of money stolen from FICREA from LEADMAN TRADE

(MEXICO) accounts held at CIBanco S.A. in Mexico to the United States, to an

account in the name of LEADMAN TRADE INC, at Wells Fargo Bank, in the

United States. Over the next several weeks, there were another 38 wires (34 to

LEADMAN TRADE INC, two to ATLYS Group Investments LLC, and one each to

AF Business Management and Consultants Inc. and Stambul LLC), for a total

of USD $4,504,576.52. These wire transfers did not correspond to any

legitimate business purpose, and were made, knowing that the funds

represented monies stolen from FICREA, for the purpose of transferring the

stolen proceeds of the scheme beyond the reach of the Plaintiff.

45. Furthermore, on July 17, 2014, LEADMAN TRADE (MEXICO) made

the first transfer of money stolen from FICREA from LEADMAN TRADE

(MEXICO) accounts held at CIBanco S.A. in Mexico to Spain, to an account in

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the name of LEADMAN TRADE ESPAÑA SRL, at Bankia, S.A., in Spain. Over

the next several weeks, there were another 24 wires (23 to LEADMAN TRADE

ESPAÑA SRL and one to “For Ocio SL” at Banco Santander S.A.), for a total of

EUR €1,226,183.72. These wire transfers did not correspond to any legitimate

business purpose, and were made, knowing that the funds represented monies

stolen from FICREA, for the purpose of transferring the stolen proceeds of the

scheme beyond the reach of the Plaintiff.

46. On September 19, 2014, the CNBV informed its Control Board of

the situation at FICREA and of possible corrective measures to be taken given

the financial and operational status of FICREA and its risk exposure.

47. From October 23, 2014, to December 18, 2014, the CNBV carried

out a second emergency Special Inspection Audit.

48. Knowing that action by the banking regulators was imminent, in

early November 2014, OLVERA AMEZCUA initiated a final series of transfers of

FICREA funds to B&J, including:

a.) On November 3, 2014: US $516,929.00;

b.) On November 4, 2014: US $2,207,010.00;

c.) On November 4, 2014: US $6,253,195.00;

d.) On November 4, 2014: US $5,149,690.00;

e.) On November 5, 2014: US $5,516,025.00;

f.) On November 5, 2014: US $3,603,803.00;

g.) On November 6, 2014: US $2,606,658.00;

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h.) On November 6, 2014: US $6,241,295.00; and,

i.) On November 6, 2014: US $2,937,080.00.

49. On November 7, 2014, the CNBV Control Board seized

management of FICREA, which was placed in temporary receivership.

50. On December 17, 2014, the CNBV was notified that FICREA was

unable to continue its operations, and would have to be dissolved and

liquidated.

51. On December 19, 2014, the CNBV revoked FICREA’s authorization

to operate as a SOFIPO.

52. On November 11, 2015, Plaintiff, JAVIER NAVARRO VELASCO,

was appointed as liquidating trustee.

53. As outlined herein, Defendants transferred funds stolen from

FICREA to bank accounts in the United States, including, but not limited to

the State of Florida. These transfers included direct transfers from FICREA,

and transfers through other entities controlled by Defendants, including B&J

and LEADMAN TRADE (MEXICO), among others. For example:

a.) As part of the scheme to defraud FICREA, OLVERA AMEZCUA

made transfers directly from FICREA to bank accounts in the United States of

funds stolen from FICREA, and in fact received such funds in the United States

on at least each of the following occasions:

i.) On June 17, 2014, a wire transfer in the amount of US

$177,912.00 from a FICREA account at CIBanco S.A. to “EXIM

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ENTERTAINMENT DIVISION LLC” (a Florida corporation) at

Sabadell United Bank, N.A.;

ii.) On June 27, 2014, a wire transfer in the amount of US

$168,000.00 from a FICREA account at CIBanco S.A. to

“SANTIAGO AGUILAR GARIBAY” at Bank of America, N.A.

b.) As part of the scheme to defraud FICREA, OLVERA AMEZCUA

transferred funds stolen from FICREA through B&J to bank accounts in the

United States, and in fact received such funds in the United States on at least

each of the following occasions:

i.) On July 3, 2013, a wire transfer in the amount of US $50,000.00

from account #***9101 at Banco Case, S.A. to an account in the

name of “RAFAEL ANTONIO OLVERA AMEZCUA” (a resident of

Florida) at Wells Fargo Bank, N.A.;

ii.) On July 3, 2013, a wire transfer in the amount of US $40,000.00

from account #***70M2 at CIBanco, S.A. to “PRESTIGE

MOTORCAR IMPORTS” at Bank of America, N.A.;

iii.) On November 5, 2013, a wire transfer in the amount of US

$125,000.00 from account #***16M2 at CIBanco S.A. to

“LEADMAN TRADE INC” (a Florida corporation with its principal

offices in this county) at Wells Fargo Bank, N.A.;

iv.) On November 5, 2013, a wire transfer in the amount of US


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“INTERIORS BY STEVEN G., INC.” (a Florida corporation) at Wells

Fargo Bank, N.A.;

v.) On March 7, 2014, a wire transfer of US $50,000.00 from account

#***09M1 at CIBanco S.A. to “YACHT GROUP INTERNATIONAL” at

Mercantile Commerce Bank;

vi.) On March 12, 2014, a wire transfer of US $50,000.00 from

account #***31M1 at CIBanco S.A. to “LT AVENTURA ONE LLC” (a

Florida corporation with its principal offices in this county);

vii.) On June 13, 2014, a wire transfer in the amount of US


“LEADMAN TRADE INC”;

viii.) On August 15, 2014, a wire transfer in the amount of US

$64,720.00 from account #***13M1 at CIBanco S.A. to BRAMAN

MOTORS (a Florida corporation) at Bank of America, N.A.;

ix.) On August 15, 2014, a wire transfer in the amount of US

$150,000.00 from account #***04M2 at CIBanco S.A. to PAUL

FELDMAN, P.A. (a Florida corporation with its principal offices in

this county);

c.) As part of the scheme to defraud FICREA, OLVERA AMEZCUA

transferred funds stolen from FICREA through LEADMAN TRADE (MEXICO) to

bank accounts in the United States and in fact received such funds in the

United States, on at least each of the following occasions:

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i.) On July 16, 2014, a wire transfer in the amount of US


“LEADMAN TRADE INC” at Wells Fargo Bank, N.A.;

ii.) On July 22, 2014, a wire transfer in the amount of US



iii.) On August 4, 2014, a wire transfer in the amount of US



iv.) On August 12, 2014, a wire transfer in the amount of US



v.) On August 21, 2014, a wire transfer in the amount of US



54. All of the transfers described above were made for the purpose of

hiding the monies stolen from FICREA outside of Mexico and outside of the

reach of the Plaintiff.

55. There is no relationship between the Defendants and FICREA that

would justify the transfers at issue.

56. Mexican banking and prosecutorial authorities promptly seized

and recovered all assets traceable to FICREA within Mexico, including real

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estate, yachts, vehicles, personal property, and bank accounts, including

assets of OLVERA AMEZCUA. However, while substantial, the recovered assets

are significantly less than the total amounts owed to FICREA.

C. The Money-Laundering “Enterprise”

57. In order to conceal, abscond with, and secure the funds stolen by

OLVERA AMEZCUA from FICREA for Defendants’ personal use and to avoid

and hamper corrective and recuperative action by the Plaintiff, the PRINCIPAL

DEFENDANTS, with the funds stolen from FICREA, created and maintained an

Enterprise consisting of a web of co-conspirators and multiple entities located

in Florida, and elsewhere, and used those entities and the funds stolen from

FICREA that had been transferred to, and received in, the United States (1) to

acquire an interest in at least 30 entities and in at least 100 real estate

properties in violation of Florida Statute § 772.103(1); (2) to maintain and

control these enterprises and real estate properties in violation of Florida

Statute § 772.103(2); and to conduct and participate in these entities through a

pattern of activity in violation of Florida Statute § 772.103(3). Examples of

these entities include:

a.) LEADMAN TRADE INC, a Florida for-profit corporation established

on July 10, 2012, and located at 20900 NE 30th Avenue, Suite

307, Aventura, Florida 33180;

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b.) LT SAN ANTONIO SERIES B LLC, a Florida limited liability

company established on May 16, 2013, and located at 20900 NE

30th Avenue, Suite 307, Aventura, Florida 33180;

c.) 2137 HAYES INC, a Florida for-profit corporation established on

January 2, 2013, and located at 20900 NE 30th Avenue, Suite

307, Aventura, Florida 33180;

d.) ROA 1406 LLC, a Florida limited liability company established on

September 10, 2014, and located at 20900 NE 30th Avenue, Suite

307, Aventura, Florida 33180; and,

e.) LT AVENTURA ONE, LLC, a Florida limited liability company

established on September 4, 2013, and located at 20900 NE 30th

Avenue, Suite 307, Aventura, Florida 33180.

58. Other entities created, maintained, and/or used by the PRINCIPAL

DEFENDANTS to assist in the acquisition, control, and/or management of the

Enterprise, and/or other persons used by the PRINCIPAL DEFENDANTS for the

acquisition, control, and/or management of the Enterprise include, but are not

limited to:

a.) LEVEL 5 SERVICES LLC,

b.) AVENSIS AGENCY LTD.,

c.) JEFFREY E. CAMPION, P.A.,

23

d.) R&S INTERNATIONAL LAW GROUP LLP, f/n/a, BRICKELL

INTERNATIONAL LAW GROUP, LLP, and d/b/a BRICKELL INTERNATIONAL

LAW GROUP,

e.) KHAVISCHAL ANAND TIWARI, ESQUIRE,

f.) EXIM ENTERTAINMENT DIVISION, LLC,

g.) INTERNATIONAL YACHT GROUP, LLC,

h.) SKELDON AGENCY, LLC.

i.) ROA ARTECH LLC,

j.) TERRALUNA INTL FLORIDA SERIES 1 LLC,

k.) TERRALUNA INTL FLORIDA SERIES 2 LLC,

l.) TERRALUNA OVERSEAS INC.,

m.) GENEVA ROTH CAPITAL, LLC,

n.) LT AEROSPACE LLC,

o.) LT CAR HOLDING LLC,

p.) LT NAUTICAL LLC,

q.) LT SAN ANTONIO SERIES A LLC,

r.) LT TRUMP II 1406 LLC,

s.) NORTH ASSET CAPITAL LLC, (a Florida corporation),

t.) ROA TRUMP 1406 LLC,

u.) ROS INVESTMENTS, LLC,

v.) ROTHSCHILD GROUP LLC,

w.) ST REGIS 2404 LLC,

24

x.) ST REGIS N 2404 LLC, and,

y.) VINDU HOLDINGS LLC.

59. In furtherance of the scheme to avoid and hamper corrective and

recuperative action by the Plaintiff, the stolen proceeds were transmitted by

Defendants to entities used in the scheme to hold title to real property.

60. Once received by these holding entities and in furtherance of the

scheme to avoid and hamper corrective and recuperative action by the Plaintiff,

the stolen funds were used by these entities to purchase real estate. Examples

of these assets include:

a.) 400 Kings Point Drive, Apartment 1515, Sunny Isles Beach,

Florida, 33160, acquired by LT COASTAL TOWERS LLC on

September 30, 2013;

b.) 1380 North Krome Avenue, Florida City, Florida 33034, acquired

by LT N 1380 KROME INC, on December 20, 2013;

c.) 20900 Northeast 30th Avenue, Suite 103, Aventura, Florida,

33180, acquired by LT 103 AVENTURA ONE LLC on January 10,

2014.

d.) 242 Riviera Circle, Weston, Florida 33327, acquired by LT

BROWARD PROPERTIES INC, on May 1, 2014.

e.) 9705 Collins Avenue, Apartment 2404N, Bal Harbour, Florida

33154, acquired by ROA BH 2404 LLC on September 12, 2014;

25

61. On an ongoing basis, OLVERA AMEZCUA, OLVERA SILVA, SILVA

TORTOLERO, LEADMAN TRADE INC, and the PROPERTY DEFENDANTS

engage in additional racketeering activity in their continued use of stolen

FICREA proceeds to manage and maintain the Enterprise, by, for example,

making tax payments, fee payments, and other payments to maintain, upkeep,

and manage the Enterprise and the real estate and personal property held

therein. Examples of such ongoing racketeering activities include, but are not

limited to:

a.) Property taxes paid to Miami-Dade County on November 25, 2014,

in the amount of US $32,680.17, for the benefit of “LT N KROME

1380 INC.” in relation to property located at 1380 N Krome

Avenue, Florida City, Florida 33034;

b.) Property taxes paid to Miami-Dade County also on November 25,

2014, in the amount of US $19,529.40, for the benefit of “LT

AVENTURA ONE LLC” in relation to property located at 20900 NE

30 Avenue, Suite 307, Aventura, Florida 33180;

c.) Property taxes paid to Miami-Dade County on November 25, 2014,

in the amount of US $32,680.17, for the benefit of “LT 103

AVENTURA ONE INC” in relation to property located at 20900

Northeast 30 Avenue, Suite 103, Aventura, Florida 33180;

d.) Property taxes paid to Miami-Dade County on May 9, 2016, in the

amount of US $18,044.00, for the benefit of “LT IDEAL

26

APARTMENTS LLC” in relation to property located 7824 Northwest

Fifth Court, Miami, Florida 33150; and,

e.) Property taxes paid to Miami-Dade County on May 12, 2016, in the

amount of US $22,689.27, for the benefit of “ROA 1406 LLC” in

relation to property located 15901 Collins Avenue, Apartment

1406, Sunny Isles Beach, Florida 33160.

62. Each act of foreign or interstate transmission by the PRINCIPAL

DEFENDANTS and the PROPERTY DEFENDANTS of funds in the amount of US

$5,000 or more, such funds having been known by the Defendants to have

been stolen from FICREA, to a place in the United States or across a state

boundary within the United States, as described herein, constituted a violation

of 18 U.S.C. § 2314.

63. Each act of reception, possession, concealment, storage, or

disposition by the PRINCIPAL DEFENDANTS and the PROPERTY

DEFENDANTS of funds in the amount of US $5,000 or more, such funds

having been known by the Defendants to have been stolen from FICREA and

transported to the United States or across a state boundary within the United

States after having been stolen, as described herein, constituted a violation of

18 U.S.C. § 2315.

64. Each financial transaction engaged in by the PRINCIPAL

DEFENDANTS and the PROPERTY DEFENDANTS with funds known by the

Defendants to have been criminal proceeds stolen from FICREA and

27

transported to the United States or across a state boundary within the United

States after having been stolen, as described herein, knowing that the

transactions were designed in whole or in part to conceal or disguise the

nature, the location, the source, the ownership, or the control of the funds,

constituted a violation of 18 U.S.C. § 1956(a)(1), (a)(2), and (a)(3).

65. Each financial transaction engaged in by the PRINCIPAL

DEFENDANTS and the PROPERTY DEFENDANTS with funds in an amount

greater than US $10,000, known by the PRINCIPAL DEFENDANTS and the

PROPERTY DEFENDANTS to have been stolen from FICREA and transported to

the United States or across a state boundary within the United States after

having been stolen, as described herein, constituted a violation of 18 U.S.C.

1957(a).

66. Through the series of bank transfers described herein and the

receipt of the monies known by the PRINCIPAL DEFENDANTS and the

PROPERTY DEFENDANTS to be funds stolen from FICREA and through the

laundering of these criminal proceeds, the PRINCIPAL DEFENDANTS and the

PROPERTY DEFENDANTS used and invested the proceeds of their illegal

activities in furtherance of the Enterprise in violation of Florida Statute §

772.103(1).



PROPERTY DEFENDANTS to be funds stolen from FICREA, and through the

28


PROPERTY DEFENDANTS acquired and controlled the Enterprise in violation

of Florida Statute § 772.103(2).



PROPERTY DEFENDANTS to be funds stolen from FICREA, and through the


PROPERTY DEFENDANTS conducted and participated in the Enterprise, in

violation of Florida Statute § 772.103(3).

69. Using the methods described herein, the PRINCIPAL DEFENDANTS

and the PROPERTY DEFENDANTS have used stolen FICREA proceeds to

acquire, control, and/or maintain substantial real and personal property,

including, but not limited to, the real property detailed in Exhibit A, attached

hereto, and the vehicles detailed in Exhibit B, also attached hereto, in violation

of Florida Statutes § 772.103(1-3).

70. The establishment, control, and maintenance of the Enterprise

required careful planning, execution, and management. The PRINCIPAL

DEFENDANTS and the PROPERTY DEFENDANTS conspired with each other to

carry out each element of the scheme and component of the Enterprise to

launder the stolen FICREA funds in violation of Florida Statute § 772.103(4) in

multiple ways, including:

29

a.) OLVERA AMEZCUA ultimately controlled and directed the

creation, establishment, and maintenance of the Enterprise, acts as director

and/or member of entities pertaining to the Enterprise, and is one of the

ultimate beneficiaries of the Enterprise’s activities;

b.) OLVERA SILVA actively participated in the creation, establishment,

and maintenance of the Enterprise, acts as director and/or member of several

entities pertaining to the Enterprise, and is one of the ultimate beneficiaries of

the Enterprise’s activities;

c.) SILVA TORTOLERO actively participated in the creation,

establishment, and maintenance of the Enterprise, and is one of the ultimate

beneficiaries of the Enterprise’s activities;

d.) LEADMAN TRADE INC, actively participated in the creation,

establishment, and maintenance of the Enterprise, acts as director and/or

member of several entities pertaining to the Enterprise, and is one of the

ultimate beneficiaries of the Enterprise’s activities, including as stockholder

and otherwise owner of multiple entities and PROPERTY DEFENDANTS;

e.) STRAUCH actively participated in the creation, establishment, and

maintenance of the Enterprise, and at all times material hereto acted as

director and/or member of several entities pertaining to the Enterprise, and is

one of the ultimate beneficiaries of the Enterprise’s activities;

f.) GALANTE actively participated in the creation, establishment, and

maintenance of the Enterprise, and at all times material hereto acted as

30

director and/or member of several entities pertaining to the Enterprise, and is

one of the ultimate beneficiaries of the Enterprise’s activities;

g.) The PROPERTY DEFENDANTS each were created, established, and

maintained as part of the Enterprise, and each PROPERTY DEFENDANT

individually holds title to one or more assets that were acquired by the

Enterprise, or are maintained, controlled, and managed by the Enterprise with

funds stolen from FICREA.

Count I:

Violation of Florida Statute § 772.103(4) by Conspiracy to Violate Florida Statutes §§ 772.103(1), (2), and (3) (As to PRINCIPAL DEFENDANTS and PROPERTY DEFENDANTS)

Plaintiff realleges paragraphs one through 68 as if fully set forth herein

and would further allege as follows:

71. At all relevant times, the Enterprise was an enterprise as defined in

Florida Statute § 772.102(3). Such Enterprise furnished a vehicle for the

commission of a pattern of racketeering activity.

72. The PRINCIPAL DEFENDANTS, the PROPERTY DEFENDANTS, and

other wrongdoers conspired, endeavored, and agreed with each other to violate

Florida Statute § 772.103(1), (2), and (3) in violation of Florida Statute §

772.103(4).

73. Specifically, the PRINCIPAL DEFENDANTS the PROPERTY

DEFENDANTS and other wrongdoers conspired, endeavored, and agreed with

31

each other: (1) to acquire entities and real property with the stolen FICREA

funds; (2) to acquire and maintain control of the Enterprise with the stolen

FICREA funds; and (3) to conduct and participate in the conduct of the affairs

of the Enterprise with the stolen FICREA funds, all through a pattern of

racketeering activity, and they agreed that two or more racketeering acts,

including the racketeering acts referred to herein—which constitute violations

of 18 U.S.C. §§ 2314 and 2315 (the transportation and receipt of stolen

property statutes), 18 U.S.C. § 1956 (the federal money-laundering statute),

and 18 U.S.C. § 1957 (the monetary transaction in criminally derived property

statute)—would be committed on behalf of the conspiracy.

74. Florida Statute § 772.102(b), specifies that “criminal activity”

includes any conduct subject to indictment or information listed in the federal

RICO statute, 18 U.S.C. § 1961(1), which includes 18 U.S.C. §§ 2314 and

2315, 18 U.S.C. § 1956 and 18 U.S.C. § 1957.

75. FICREA has been injured as a direct and proximate result of the

foregoing conspiracy to violate Florida Statutes §§ 772.103(1), (2), and (3) in


WHEREFORE, Plaintiff, JAVIER NAVARRO VELASCO, as Trustee of

FICREA, demands judgment, jointly and severally, against the PRINCIPAL

DEFENDANTS and the PROPERTY DEFENDANTS, pursuant to Florida Statute

§ 772.104(1) for treble damages, interest, attorneys’ fees, the costs of this

action, and for injunctive relief pursuant to Florida Statute § 895.05(6),

32

including the imposition of a constructive trust, disgorgement, and such other

and further relief as the Court shall deem just and appropriate.

Count II

Violations of Florida Statutes §§ 772.103(1), (2), and (3)

(As to PRINCIPAL DEFENDANTS and PROPERTY DEFENDANTS)



76. At all relevant times, the Enterprise was an enterprise as defined in

Florida Statute § 772.102(3).

77. By engaging in the transactions set forth herein, the PRINCIPAL

DEFENDANTS and the PROPERTY DEFENDANTS transferred funds from

FICREA to the accounts in financial institutions in the United States via wire

and used those monies to fund the operations of the Enterprise. These

unlawful wire transfers and the use of stolen FICREA proceeds violated 18

U.S.C. §§ 2314 and 2315 (the transportation and receipt of stolen property

statutes), 18 U.S.C. § 1956 (the federal money-laundering statute), and 18

U.S.C. § 1957 (the monetary transaction in criminally derived property statute),

and constituted a pattern of racketeering activity.


other wrongdoers used and invested the income and proceeds generated from

this pattern of racketeering activity and further racketeering activity to acquire

33

and establish entities and purchase real estate in violation of Florida Statute §

772.103(1).



this pattern of racketeering activity and further racketeering activity to

maintain and control the acquired entities and the purchased real estate in




this pattern of racketeering activity and further racketeering activity to conduct

and participate in the management of the entities and the purchased real

estate in violation of Florida Statute § 772.103(3).

81. Plaintiff has been injured in its business and property as a direct

and proximate result of the foregoing violations of Florida Statutes §§

772.103(1), (2), and (3) through the Enterprise.



DEFENDANTS and the PROPERTY DEFENDANTS, pursuant to Florida Statute

§ 772.104(1) for treble damages, interest, attorneys’ fees, the costs of this

action, and for injunctive relief pursuant to Florida Statute § 895.05(6),

including the imposition of a constructive trust, disgorgement, and such other

and further relief as the Court shall deem just and appropriate.

34

Count III

Violation of the Florida Uniform Fraudulent Transfer Act (As to PRINCIPAL DEFENDANTS, PROFESSIONAL DEFENDANTS, and

PROPERTY DEFENDANTS)



82. This is a claim to avoid and recover fraudulent transfers pursuant

to Florida Statute § 726.105.

83. Defendant OLVERA AMEZCUA transferred at least US

$65,000,000 stolen from FICREA to the PRINCIPAL DEFENDANTS, the

PROFESSIONAL DEFENDANTS, the PROPERTY DEFENDANTS, and others.

84. In turn, the PROFESSIONAL DEFENDANTS transferred said sums

for, among other purposes, the purchase, control, and/or maintenance of

assets by and for the benefit of the PRINCIPAL DEFENDANTS, the PROPERTY

DEFENDANTS, and others.

85. At the time of each of these transfers, Defendant, OLVERA

AMEZCUA, was operating FICREA for his own personal profit. The transfers

constituted transfers of value from FICREA which did not belong to OLVERA

AMEZCUA and were not made for value. The transfers were made to fund

bank accounts in the name of the PRINCIPAL DEFENDANTS, the

PROFESSIONAL DEFENDANTS, the PROPERTY DEFENDANTS, and others at

multiple banks, and a significant portion of these funds was later used to fund

35

the PROPERTY DEFENDANTS. As a result, FICREA became a creditor of the

PRINCIPAL DEFENDANTS, the PROFESSIONAL DEFENDANTS, and the

PROPERTY DEFENDANTS for purposes of this claim.

86. These transfers to the PRINCIPAL DEFENDANTS, the

PROFESSIONAL DEFENDANTS, the PROPERTY DEFENDANTS, and others,

were made with actual intent to hinder, delay, and defraud FICREA.

87. As a direct and proximate result of the fraudulent transfers to the

PRINCIPAL DEFENDANTS, the PROFESSIONAL DEFENDANTS, the PROPERTY

DEFENDANTS, and others, FICREA has been diminished, and the remaining

assets of FICREA are insufficient to pay FICREA’S liabilities, principally to its

depositors.


FICREA, requests an order from this Court: (a) avoiding the transfers made by

OLVERA AMEZCUA to the PRINCIPAL DEFENDANTS, the PROFESSIONAL

DEFENDANTS, and the PROPERTY DEFENDANTS and others; (b) attaching the

assets transferred; the assets acquired by the PRINCIPAL DEFENDANTS, the

PROFESSIONAL DEFENDANTS, and the PROPERTY DEFENDANTS with funds

stolen from FICREA; and any income produced by any such assets acquired

with funds stolen from FICREA; (c) enjoining against further disposition against

the PRINCIPAL DEFENDANTS, the PROFESSIONAL DEFENDANTS, and the

PROPERTY DEFENDANTS, or any transferee of the transferred assets; and (d)

36

awarding interest, the costs of this action, and such further relief as this Court

shall deem proper.

Count IV

Conversion (As to PRINCIPAL DEFENDANTS and PROPERTY DEFENDANTS)



88. FICREA was in lawful possession of valuable assets, including all

of the deposits and investments owned and held by FICREA.

89. The PRINCIPAL DEFENDANTS and the PROPERTY DEFENDANTS,

through unauthorized and improper means, have wrongfully asserted dominion

over the property of the Plaintiff and have wrongfully deprived the Plaintiff of

the right to possess and use its property for a permanent or indefinite term.

90. At all times material hereto, the PRINCIPAL DEFENDANTS and the

PROPERTY DEFENDANTS acted with the intent to deprive Plaintiff of the

possession and use of its property.

91. Plaintiff has suffered damages as a result of the acts of the

PRINCIPAL DEFENDANTS and the PROPERTY DEFENDANTS, including losses

in excess of US $65,000,000.



DEFENDANTS and the PROPERTY DEFENDANTS, as well as the costs of this

37

action, and such other and further relief as the Court shall deem just and

appropriate.

Count V

Unjust Enrichment/Constructive Trust (As to PRINCIPAL DEFENDANTS and PROPERTY DEFENDANTS)



92. The PRINCIPAL DEFENDANTS and the PROPERTY DEFENDANTS

have benefited from their unlawful acts and conspiracy through the receipt and

laundering of at least US $ 65,000,000, which was the rightful property of the

Plaintiff.

93. The PRINCIPAL DEFENDANTS and the PROPERTY DEFENDANTS

improperly received funds from Plaintiff as a result of the deliberate acts of the

PRINCIPAL DEFENDANTS and the PROPERTY DEFENDANTS when in fact

those funds did not belong to them, but rather were owned by FICREA.

94. It would be inequitable for the PRINCIPAL DEFENDANTS and the

PROPERTY DEFENDANTS to be permitted to retain the benefit of their

wrongful conduct.

95. The Plaintiff is entitled to the establishment of a constructive trust

consisting of the ill-gotten gains received by the PRINCIPAL DEFENDANTS, the

PROPERTY DEFENDANTS, and any purchases of real or personal property

38

made with the ill-gotten gains or profits traceable to the stolen FICREA funds

to be disgorged or otherwise paid or conveyed to Plaintiff.



DEFENDANTS and the PROPERTY DEFENDANTS for

disgorgement/restitution/conveyance of the ill-gotten gains and of any real or

personal property purchased therewith, and for the costs of this action, and

such other and further relief as the Court shall deem just and appropriate.

Count VI

Breach of Fiduciary Duty (As to OLVERA AMEZCUA)



96. As the President of FICREA, Defendant, OLVERA AMEZCUA, owed

a fiduciary duty to FICREA to act in FICREA's, and not his own, best interest.

97. This fiduciary duty included the duty of loyalty and the duty to act

in good faith, dealing fairly with FICREA.

98. OLVERA AMEZCUA breached his fiduciary duty by taking (and

continuing to take) actions contrary to the interests of FICREA, including but

not limited to receiving, maintaining, and laundering funds that were rightfully

earned and owned by FICREA, but which OLVERA AMEZCUA used to fund

new businesses and acquire real and personal property for his own benefit.

39

99. OLVERA AMEZCUA's actions damaged FICREA’s ability to carry on

its business and eventually resulted in its liquidation.

100. As a direct and proximate result of OLVERA AMEZCUA's breach of

fiduciary duties, Plaintiff has suffered damages as described herein.


FICREA, demands judgment against Defendant, OLVERA AMEZCUA, together

with the costs of this action, and such other and further relief as the Court

shall deem just and appropriate.

Count VII

Aiding and Abetting Breach of Fiduciary Duty (As to OLVERA SILVA, SILVA TORTOLERO,

LEADMAN TRADE INC, GALANTE, STRAUCH, PROFESSIONAL DEFENDANTS and PROPERTY DEFENDANTS)



101. As the President of FICREA, Defendant, OLVERA AMEZCUA, owed

a fiduciary duty to FICREA to act in FICREA's, and not his own, best interest.

102. Defendants, OLVERA SILVA, SILVA TORTOLERO, LEADMAN

TRADE INC, GALANTE, STRAUCH, PROFESSIONAL DEFENDANTS, and

PROPERTY DEFENDANTS, each knew that OLVERA AMEZCUA owed such

fiduciary duty and knew that Defendant, OLVERA AMEZCUA, breached his

duty because Defendants, OLVERA SILVA, SILVA TORTOLERO, LEADMAN

TRADE INC, GALANTE, STRAUCH, PROFESSIONAL DEFENDANTS, and

40

PROPERTY DEFENDANTS each knew that FICREA was the lawful owner of the

funds used by OLVERA AMEZCUA to start businesses and purchase real and

personal property for himself and his family.

103. Defendants, OLVERA SILVA, SILVA TORTOLERO, LEADMAN

TRADE INC, GALANTE, STRAUCH, the PROFESSIONAL DEFENDANTS, and

the PROPERTY DEFENDANTS each knowingly participated in the transfer

and/or receipt of funds and OLVERA AMEZCUA’S breach of fiduciary duty by

receiving, transferring, and/or otherwise helping OLVERA AMEZCUA hide

FICREA funds in United States bank accounts to be used to start new

businesses and acquire real and personal property for the benefit of the

PRINCIPAL DEFENDANTS and the PROPERTY DEFENDANTS.

104. Without the assistance of Defendants, OLVERA SILVA, SILVA

TORTOLERO, LEADMAN TRADE INC, GALANTE, STRAUCH, the

PROFESSIONAL DEFENDANTS and the PROPERTY DEFENDANTS, Defendant,

OLVERA AMEZCUA, could not have successfully transferred and/or received

FICREA’S funds into United States bank accounts to be used to start new

businesses and/or to acquire real and personal property for the benefit of the

PRINCIPAL DEFENDANTS and the PROPERTY DEFENDANTS.

105. As a direct and proximate result of Defendants, OLVERA SILVA,

SILVA TORTOLERO, LEADMAN TRADE INC, GALANTE, STRAUCH, the

PROFESSIONAL DEFENDANTS, and the PROPERTY DEFENDANTS each aiding

41

and abetting the breach of fiduciary duty, Plaintiff has suffered damages as

described herein.


FICREA, demands judgment, against Defendants, OLVERA SILVA, SILVA

TORTOLERO, LEADMAN TRADE INC, GALANTE, STRAUCH, PROFESSIONAL

DEFENDANTS, and PROPERTY DEFENDANTS, each, together with the costs of

this action, and such other and further relief as the Court shall deem just and

appropriate.

Demand for Jury

Plaintiff, JAVIER NAVARRO VELASCO, as Trustee of FICREA S.A. DE

C.V. SOCIEDAD FINANCIERA POPULAR (In Liquidation) demands trial by jury

of all issues triable as of right by jury.

Dated: September 20, 2016.

KRUPNICK, CAMPBELL, MALONE, BUSER, SLAMA, HANCOCK, LIBERMAN, P.A. By: /s/ Carlos A. Acevedo Carlos A. Acevedo, Esquire Florida Bar Number: 0097771 [email protected] Kevin A. Malone, Esquire Florida Bar Number: 224499 [email protected] Kelley B. Stewart, Esquire Florida Bar Number: 492132

42

[email protected] Michael J. Ryan, Esquire Florida Bar Number: 975990 [email protected] 12 Southeast Seventh Street, Suite 801 Fort Lauderdale, Florida 33301-3434 954-763-8181 telephone 954-763-8292 facsimile Attorneys for Plaintiff

43

Exhibit A Address: Apt/Ste/Unit: City: State: Zip: 3301 NE 183 St 2401 Aventura FL 33160 20900 NE 30 AVE 103 Aventura FL 33180 20900 NE 30 AVE 307 Aventura FL 33180 2950 NE 188 ST 150 Aventura FL 33180 2950 NE 188 ST 212 Aventura FL 33180 2950 NE 188 ST 244 Aventura FL 33180 2950 NE 188 ST 403 Aventura FL 33180 2950 NE 188 ST 405 Aventura FL 33180 2950 NE 188th Street 545 Aventura FL 33180 9705 Collins Ave 2404N Bal Harbour FL 33154 5880 W Sample Road 101 Coral Springs FL 33067 1210 NW 9 CT Florida City FL 33034 1211 NW 9 CT Florida City FL 33034 1230 NW 9 CT Florida City FL 33034 1231 NW 9 CT Florida City FL 33034 1251 NW 9 CT Florida City FL 33034 1270 NW 9 CT Florida City FL 33034 1271 NW 9 CT Florida City FL 33034 1310 NW 9 CT Florida City FL 33034 1311 NW 9 CT Florida City FL 33034 1331 NW 9 CT Florida City FL 33034 1351 NW 9 CT Florida City FL 33034 1370 NW 9 CT Florida City FL 33034 1371 NW 9 CT Florida City FL 33034 1380 N. Krome Avenue Florida City FL 33034 800 Parkview Dr 901 Hallandale FL 33009 2137 Hayes Street Hollywood FL 33023 6015 Washington Street Parcel A Hollywood FL 33023 6015 Washington Street Parcel B Hollywood FL 33023 225 S B Street 1 Lake Worth FL 33460 3071 NW 43rd Street Lauderdale Lakes FL 33309 3396 Orinoco Lane Margate FL 33063 6308 Duval Drive Margate FL 33063 150 SE 2 AVE 105 Miami FL 33131 150 SE 2 AVE 201 Miami FL 33131 150 SE 2 AVE 202 Miami FL 33131 150 SE 2 AVE 203 Miami FL 33131

44

150 SE 2 AVE 204 Miami FL 33131 150 SE 2 AVE 205 Miami FL 33131 150 SE 2 AVE 206 Miami FL 33131 150 SE 2 AVE 207 Miami FL 33131 150 SE 2 AVE 208 Miami FL 33131 150 SE 2 AVE 209 Miami FL 33131 1800 N BAYSHORE DR 807 Miami FL 33132 1800 N BAYSHORE DR 2403 Miami FL 33132 2899 Collins Avenue 1425 Miami FL 33140 7824 NW 5 CT Miami FL 33150 77 NW 77 ST Miami FL 33180 12124 St Andrews Place 309 Miramar FL 33025 12130 St Andrews Place 205 Miramar FL 33025 2300 NW 33rd Street 903 Oakland Park FL 33309 12512 Crest Springs Ln 1123 Orlando FL 32828 12603 Crest Springs Ln 1411 Orlando FL 32828 12603 Crest Springs Ln 1412 Orlando FL 32828 12603 Crest Springs Ln 1414 Orlando FL 32828 12603 Crest Springs Ln 1417 Orlando FL 32828 712 Crest Pines Dr 311 Orlando FL 32828 712 Crest Pines Dr 322 Orlando FL 32828 725 Crest Pines Dr 411 Orlando FL 32828 802 Crest Pines Dr 818 Orlando FL 32828 415 SW 113 Way 415 Pembroke Pines FL 33025 217 SW AVONDALE DRIVE #1-6 Pompano Beach FL 33060 1920 W BLUE HERON BLVD Riviera Beach FL 33404 3039 Avenue J 1 Riviera Beach FL 33404 3115 Avenue J A Riviera Beach FL 33404 100 BAYVIEW DRIVE 321 SUNNY ISLES BEACH FL 33160 15901 COLLINS AVE 1401 Sunny Isles Beach FL 33160 15901 COLLINS AVE 1406 Sunny Isles Beach FL 33160 400 KINGS POINT DR 107 Sunny Isles Beach FL 33160 400 KINGS POINT DR 304 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 326 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 415 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 628 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 703 Sunny Isles Beach FL 33160 400 KINGS POINT DR 708 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 809 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 1114 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 1215 SUNNY ISLES BEACH FL 33160

45

400 KINGS POINT DR 1230 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 1507 SUNNY ISLES BEACH FL 33160 400 KINGS POINT DR 1515 SUNNY ISLES BEACH FL 33160 500 BAYVIEW DRIVE 421 SUNNY ISLES BEACH FL 33160 4502 Woodland Circle Tamarac FL 33319 2174 Ensenada Terrace Weston FL 33327 242 Riviera Circle Weston FL 33327 200 W SAHARA AVE 3705 Las Vegas NV 89102 5018 Summit Pass San Antonio TX 78229 3519 Paesanos Parkway San Antonio TX 78231 5005 Stowers Blvd San Antonio TX 78238 5007 Stowers Blvd San Antonio TX 78238 7815 Kingsbury Way San Antonio TX 78240 7819 Kingsbury Wood San Antonio TX 78240 7822 Kingsbury Way San Antonio TX 78240 8615 Kingsbury View San Antonio TX 78240 6613 Biscay Bay San Antonio TX 78249 6643 Biscay Bay San Antonio TX 78249 6748 Biscay Bay San Antonio TX 78249 1214 Sunset View San Antonio TX 78258 19218 Stone Oak Pkwy San Antonio TX 78258 1103 Olympic Club San Antonio TX 78260 1115 Links Cove San Antonio TX 78260 1220 Links Ln San Antonio TX 78260 1228 Links Lane San Antonio TX 78260 1247 Links Lane San Antonio TX 78260 2018 Sawgrass Ridge San Antonio TX 78260 2115 Sawgrass Rdg San Antonio TX 78260 2227 Sawgrass Ridge San Antonio TX 78260 2243 Winding View San Antonio TX 78260 25118 Callaway San Antonio TX 78260 25319 Bunker Drive San Antonio TX 78260 26922 Villa Toscana San Antonio TX 78260 3823 Olive Green San Antonio TX 78260

46

Exhibit B

List of vehicles:

1. Automobiles: Year Make Model VIN # Issuing State 1997 Dodge Ram 1500 3B7HC13Z8VG716478 Texas 2005 Ferrari F430 ZFFEW58A850142085 Florida 2008 Lamborghini Gallardo ZHWGU22TX8LA07340 Florida 2010 Rolls Royce Ghost SCA664S50AUX49102 Florida 2010 Ferrari California ZFF65LJA1A0169354 Florida 2011 Maserati Granturismo ZAM45KMA7B0054265 Texas 2011 Mali BT 5A7BB2228BT000865 Texas 2012 Lamborghini Gallardo ZHWGU5BZ9CLA11829 Florida

2013 Chevorlet Suburban 1500 1GNSCKE07DR230163 Florida

2013 Infinity JX35 5N1AL0MN5DC319654 Texas

2013 Chevorlet Suburban 1500 1GNSCKE0XDR211462 Texas

2013 Chevorlet Silverado 1500 3GCPCTE0XDG103542 Texas

2014 Mercedes Benz S63

WDDUG7JB5EA062622 Florida

2014 Honda CRV 2HKRM3572EH534402 Texas 2014 Maserati Granturismo ZAM45VLA5E0090981 Texas 2014 Porsche 911 WP0AA2A97ES107858 Texas

2014 EZGO MV 3069961 Unknown/ Not Available

2016 Porsche Cayenne WP1AB2A20GLA96844 Texas

2016 Mercedes Benz GL550 4JGDF7DE8GA674203 Texas

2017 Porsche 911 WP0AB2A94HS123131 Texas

2. Watercraft:

Year Make Hull ID Registration Number

Registration State

2011 Malibu MB2K3092J011 2883CR Texas

Documents

Filing # 46667693 E-Filed 09/20/2016 12:30:33 PM11. Defendant, PAUL FELDMAN, P.A., is a Florida corporation with its principal place of business at 2750 Northeast 185th Street, Suite